As a compliance officer, I often find that many lessons come from enforcement actions. Those actions imposed on compliance officers are especially instructive. The latest to catch my attention comes from the United Kingdom. The Financial Services Authority levied a £14,000 fine and banned a compliance officer from performing any significant influence function in regulated [...]
Tag Archives: United Kingdom
The London Olympics and the Bribery Act
The London Olympics in 2012 will be a test of strength, agility and endurance. That’s just be for the corporate sponsors trying to comply with the UK’s Bribery Act. Unlike the US Foreign Corrupt Practices Act, the UK’s Bribery Act applies equally to payments made to foreign government officials as it does to payment made [...]
Adequate Procedures to Prevent Bribery in the UK
On 14 September 2010, the United Kingdom’s Ministry of Justice issued its Consultation Paper on what might be “adequate procedures” prevent bribery. Under section 9 of the Bribery Act, the only defense against criminal liability for a commercial organization which has “failed to prevent bribery” is that the organization had adequate procedures” to prevent bribery. [...]
UK Bribery Act Delayed
When I saw there was a press release from the UK’s Ministry of Justice, I was expecting an announcement of what it meant for a commercial organization to have “adequate procedures” to prevent bribery. That being the only affirmative defense under the Bribery Bill. It turns out that implementation of the Bribery Act will be [...]
Bribery in Britain
The British government is working on a new Bribery Bill “to reform the criminal law of bribery to provide for a new consolidated scheme of bribery offenses to cover bribery both in the United Kingdom (UK) and abroad.” The Bribery Bill would replaces the offenses under the Public Bodies Corrupt Practices Act 1889, the Prevention [...]
One in Two U.K. Companies Block Social Networking Web Sites
Fulbright & Jaworski, the international law firm, just published their 6th Annual Litigation Trends Survey Report. It is an independent survey of senior corporate counsel from a wide range of industry sectors. About half of the respondents (52% of U.K. and 46% of U.S.) claim to block employees from accessing social networking Web sites. Two [...]
Self-Reporting Corruption in the UK
As part of its renewed efforts to combat overseas corruption, the United Kingdom’s Serious Fraud Office published its new Approach of the Serious Fraud Office to Dealing with Overseas Corruption . Previously, the Serious Fraud Office saw its role as an after-the-event investigator and prosecutor, difficult for a company to engage except in the context [...]
FCPA Opinion Procedure Release 08-02
FCPA Opinion Procedure Release 08-02 came at the request of Halliburton and its subsidiaries as they are looking to buy a UK well flow management company. They did not have enough time to complete the appropriate FCPA diligence on the target. Halliburton was concerned about inheriting FCPA liability as a result of its acquisition of [...]
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